Navigating Labor Compliance on DBRA Projects: Practical Tips for Compliance Professionals
Davis-Bacon and Related Acts (DBRA) projects are a cornerstone of federally-assisted construction, ensuring workers are paid fairly and equitably. But as compliance professionals, we know the challenges that come with enforcing these standards.
While drafting the onboarding manual for the City of Tucson's new compliance team members, I was reminded just how important it is to proactively address common pitfalls. Here’s a quick guide to the top challenges compliance professionals face—and the strategies to mitigate them
Misclassifying Worker Roles
The Issue: Misclassification during site reviews can lead to worker disputes and violations.
The Fix: Verify alignment between job duties observed on-site and the project’s wage determination. For unclear cases, initiate a DOL conformance request.
Incomplete or Inaccurate Certified Payroll Reports (CPRs)
The Issue: Missing data on WH-347 forms often leads to rework and delays.
The Fix: Implement a rigorous review process for CPR submissions, focusing on hours, classifications, and deductions. Using platforms like LCPtracker and eComply simplify error detection.
Fringe Benefit Documentation Gaps
The Issue: Inconsistent fringe reporting often leads to underpayment issues.
The Fix: Train contractors on documenting benefits consistently—whether paid directly to employees or into approved plans—and require this in CPR submissions.
Site Interview Discrepancies
The Issue: Worker interviews often reveal misalignments with payroll records.
The Fix: Regularly reconcile site interviews with CPRs to flag and resolve discrepancies before audits.
Missing Certified Payroll Deadlines
The Issue: Late submissions complicate oversight and risk penalties.
The Fix: Establish clear submission schedules with contractors and leverage automated reminders to ensure timely reporting.
Inadequate Record-Keeping
The Issue: Missing or incomplete records create vulnerabilities during audits.
The Fix: Encourage contractors to maintain secure storage of payroll records for at least three years post-project completion.
I’m excited to see the City of Tucson’s compliance team start work with knowledge and support, and I’m proud to have contributed to their onboarding efforts.
As compliance professionals, our role is to ensure not only adherence to DBRA standards but also a fair and equitable process for all stakeholders. Tools like LCPtracker, eComply, and Elations, regular training, and proactive monitoring are essential to making compliance manageable and effective.
